Facts:

The case revolves around the petition of Rosalino L. Marable (Petitioner) against Myrna F. Marable (Respondent) regarding the validity of their marriage. They were initially classmates at Arellano University, where their relationship developed in 1967. After eloping, they married civilly on December 19, 1970, in Tanay, Rizal, followed by a church wedding on December 30, 1970, at the Chapel of the Muntinlupa Bilibid Prison. They had five children together. Unfortunately, as time progressed, their marriage was marked by increasing verbal and physical conflicts, especially following issues with their children, including a transfer due to juvenile misconduct and a teenage pregnancy. This turmoil led to continuous disputes between the couple.

Petitioner felt unloved and unappreciated, eventually causing him to engage in an extramarital relationship. Although he ended this affair upon Respondent's discovery, their relationship continued to deteriorate, compounded by failed busine

...

Facts:

Background and Marriage:

• Petitioner Rosalino L. Marable and respondent Myrna F. Marable met in 1967 while studying at Arellano University. They became sweethearts despite petitioner having another girlfriend at the time.
• They eloped and were married in civil rites on December 19, 1970, followed by a church wedding on December 30, 1970. Their marriage produced five children.

Marital Issues:

• Over time, their marriage deteriorated, marked by frequent verbal and physical quarrels. The situation worsened due to their eldest daughter’s juvenile misconduct and teenage pregnancy.
• Petitioner felt unloved and unappreciated, leading him to develop a relationship with another woman. Although he ended the affair after respondent discovered it, their marital problems persisted.
• Their business ventures failed, and frequent arguments eroded any remaining respect between them. Petitioner eventually left the family home, gave up their properties, and converted to Islam.

Petition for Nullity:

• On October 8, 2001, petitioner filed a petition to declare his marriage null and void, claiming psychological incapacity under Article 36 of the Family Code.
• He alleged that his psychological incapacity stemmed from his troubled childhood, including his father’s gambling, womanizing, and abandonment of the family. He claimed this led to his obsession with attention and inability to fulfill marital obligations.
• Petitioner presented a psychological report by Dr. Nedy L. Tayag, who diagnosed him with "Antisocial Personality Disorder," characterized by social deviancy, impulsivity, self-centeredness, and lack of remorse. Dr. Tayag concluded that petitioner was psychologically incapacitated to perform marital obligations.

Trial Court Decision:

• The Regional Trial Court (RTC) granted the petition, declaring the marriage null and void based on petitioner’s psychological incapacity.

Court of Appeals Decision:

• The Court of Appeals (CA) reversed the RTC decision, holding that petitioner failed to sufficiently prove his psychological incapacity. The CA noted that Dr. Tayag’s report lacked a clear explanation of the root cause and permanence of the disorder.

Issue:

1. Whether the Court of Appeals erred in reversing the RTC’s decision declaring the marriage null and void on the ground of petitioner’s psychological incapacity.
2. Whether petitioner’s psychological incapacity was sufficiently proven to meet the legal requirements under Article 36 of the Family Code.

---

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Conclusion:

The Supreme Court upheld the validity of the marriage, finding that petitioner failed to meet the stringent requirements for proving psychological incapacity under Article 36 of the Family Code. The decision emphasizes that psychological incapacity must be grave, rooted in a psychological disorder existing at the time of the marriage, and proven with sufficient medical or clinical evidence.